On Friday, November 9^th, FIF submitted comments on FINRA’s recent proposal to expand Equity Trading Volume Data published on FINRA’s website.  FIF’s comments focused on the definition of a Single Dealer Platform and the Proposed Rule’s requirements of mandating firms operating a SDP obtain an additional MPID. To review the letter, please click here.

FIF met with the SROs in-person on November 7th to discuss phase 2c representative order linkage reporting requirements to walk through current business practices in order to provide recommendations to allow OMS/EMS systems to capture and report phase 2c CAT reportable information.  Similarily, this Wednesday, FIF will meet with the SROs/ThesysCAT to discuss the remaining challenges related to FDID. 

On Friday, November 2nd, the SEC issued a final rule require additional disclosures by broker-dealers to customers regarding the handling of their orders.  Specfically, the Commission is adding a new disclosure requirement which requires a broker-dealer, upon request of its customer, to provide specific disclosures related to the routing and execution of the customer’s NMS stock orders submitted on a not held basis for the prior six months, subject to two de minimis exceptions and is also is amending the current order routing disclosures that broker-dealers must make publicly available on a quarterly basis to pertain to NMS stock orders submitted on a held basis, and the Commission is making targeted enhancements to these public disclosures.  FIF is forming a working group to assist firms with the implementation of the new disclosure of Order Handling Information rules.

Following the publication of the CAT Industry Member Technical Specification on October 30th, FIF has formed a CAT Tech Spec Requirements Working Group to 1) review and suggest additional business scenarios/FAQs to the SROs; and 2) assist firms during the implementation process of the CAT.  If you would like to join this working group, please send an email to fifinfo@fif.com or register here.

On Tuesday, October 30th, a contingent of FIF members representing retail broker-dealers, whole market makers, and an analytics provider along with FIF staff met with the SEC Division or Trading and Markets and Staff to Chair Clayton and Commissioner Peirce to discuss SEC Rule 605 modernization recommendations.  FIF will review the content of the meetings and propose next steps during the FIF Rule 605 subgroup meeting on Monday, November 5th @ 1:00 pm.